The Spanish Government has released draft legislation to modify the country's transfer pricing documentation rules, including the introduction of a country-by-country (CbC) reporting requirement. As drafted, the new rules closely follow the guidelines developed as part of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) Project, which includes a new CbC report.
The CbC reporting requirement would apply for Spanish resident entities that are the head of a corporate group and are …